A process that appears designed to intentionally disenfranchise a population with which it is supposed to promote dialogue can only be looked at with skepticism and must be considered a ruse and a sham. Although the model as presented for public comment regarding the request for a twenty year license extension for the Palisades Nuclear Plant in Van Buren County, Michigan, meets guidelines as established by the NRC, it provides little opportunity and draconian deadlines for true citizen participation to exist. Such restrictions may have been dismissed by communities in which other license renewals have been requested and approved, but I submit that Southwest Michigan holds itself to higher standards and wishes to challenge the industry paradigm and demand a more reasonable and humane response to this license renewal process than the flawed one that has been foisted upon us.

Current standards only allow for easy participation from persons living within the industry-designated ten mile radius emergency planning zone. Obviously radiation travels far greater distances than that, and even the extended 50 mile radius does not realistically encompass the distance a radiation release can travel. Meetings have been scheduled only in the South Haven area with limited publicity and at times that impede a working public's ability to attend. These dates and locations may be convenient for Palisades representatives and NRC staff but not to residents in the greater area affected by the plant's existence. For example, the next public meeting in which these and other comments submitted by today's deadline will be discussed is scheduled for the Friday before Labor Day. This insults the public, inhibits participation by interested citizens and denigrates the integrity of the process.

Materials pertinent to the license currently available only at the South Haven library should be made available in a majority of libraries located within the 50 mile radius. The whole process needs to be expanded to include public meetings and comment opportunities in all communities within the entire 50 mile radius who wish to request them. If the plant owners and managers have nothing to hide and take pride in their operation, then they should have no reservations about taking their meetings on the road and extending the process to a more reasoned pace. And if the NRC believes in the integrity of their process, they should likewise be up to this challenge. It is six years before the current license expires. There is no need to rush through the process. In fact, a more lengthy approach that is truly inclusive of citizen participation from affected communities should be encouraged.

Let us not forget that we are discussing the continued production for another 20 years of a lethal waste that requires extreme safety control measures. We are not talking about a tootsie roll factory here. The waste product is being stored on the shores of a body of water that constitutes one fifth of the earth's surface fresh water and which provides potable water to millions of people. Another twenty years of accumulated waste added to the already existing lineup of outdoor dry cask storage situated on unstable sand dunes is a major concern.

It has been recently confirmed by the National Academy of Science that there is no safe level of exposure to radiation and that even very low doses can cause cancer. I am therefore disturbed by nuclear industry corporate culture that has a ubiquitous record of dismissing legitimate concerns about radiation exposures. In the case of Three Mile Island, it has been found by more recent independent analysis of the 1979 accident that placement and frequency of monitoring devices were highly inadequate and unable to establish accurate data from which to establish radiation release patterns. For residents of Harrisburg and the surrounding area, that meant their reported symptoms of metallic taste, erythema, nausea, vomiting diarrhea, hair loss, deaths of pets and farm animals were attributed to stress brought on by the accident, not radiation releases from the accident. Apparently if no monitors were present in any given neighborhood and therefore no radiation data could be collected, then no radiation had been released. People were treated as though they had psychological problems, not legitimate symptoms of radiation exposure.

Exactly how will the citizens of Michigan be treated should a similar accident occur at Palisades? I simply refuse to accept my community being treated in such an insulting and degrading manner. I therefore ask that a complete map showing existing radiation detection locations for Palisades be provided and frank discussion on this monitoring methodology be initiated. I also ask that public health data regarding cancer rates in surrounding communities of the Palisades Nuclear Plant be included in the discussion, and participation by Michigan Department of Community Health epidemiologists be present at future hearings.

I also request that information reflecting the true financial taxpayer economic burden of the plant, including all anticipated guaranteed loans, tax incentives, and any other additional financial deals expected to be requested by plant owners that are contingent upon Palisades' continued operation, be provided at some point in the proceedings, or the means and process to obtain such data be provided. While I realize that this is not germane to the Environmental Impact Statement, disclosure of this information is vital to assessing Palisades' true financial worth to the community.

This aging, embrittled nuke needs to be shut down. The NRC re-licensed the aging nuclear reactor for another 20 years. That will be 60 years running, if it doesn't blow up first. The reactor was designed and built for 20 years. The NRC is rubber-stamping the re-licensing of nuclear reactors throughout the USA. Nuclear energy is not a solution to global warming. In the process of mining uranium, processing uranium, transporting nuclear fuel, building and running nuclear power plants, nuclear waste production, transportation, and dumping....tremendous amounts of fossil fuels are used, and the lake/river waters used to cool down nuclear reactions creates water heating, atmospheric heating and radioactive elemental releases into the environment.

A coalition of environmental groups, including Don't Waste Michigan has filed a lawsuit in federal courts because the re-licensing did not take into account some very important issues.

The area surrounding Palisades is a cancer pocket. If you live in that area, and have cancer, know someone with cancer, or someone who has died from cancer, your testimony is especially crucial to the shut down. The goal of DWM is to shut it down before it melts down. Members of DWM have regularly attended meetings with the NRC with the purpose of bringing issues to light, getting testimony on the federal record, and to shut down unsafe nuclear reactors.

A former Palisades worker gave his opinion: that 'within the nuclear industry, it is well known that Palisades is the most likely to blow of all nuclear reactors in the United States....they don't necessarily cover things up, they just don't report them'

~name withheld by request~

DWM members have brought it to the attention of the NRC and Homeland Security the need for more security surrounding and within nuclear reactors. Even without a terrorist attack, the mere operation of a nuclear reactor is a potential terrorist act, if a meltdown should occur.

Consumers Energy sold Palisades to Entergy.*

DWM feels that a sustainable future can only be realized with safe, renewable energy systems, such as wind, water, and solar power.

When the South Haven mayor spoke out that the people of South Haven wanted the nuclear power plant, citizens rose in protest. "He does not speak for us! There is a cancer pocket here!"

In November, he was not re-elected, losing by 70%...

The people have spoken!

Palisades issues:

Embrittlement

Global warming caused by nuclear energy

Cask problems (nuclear waste storage)

Nuclear accidents

The threat of terrorism

etc......public comments were truncated and edited in the EIS. by the NRC.

UPDATE 2007: The NRC rubberstamped the re-licensing of Palisades without allowing the public meetings as promised in winter/spring of 2007. The NRC never answered all of the questions put forth by DWM re: embrittlement, cask #4 (bad welds), nuclear waste buildup, rad waste spills, terrorism, and other issues.

*UPDATE 2008: ENTERGY sold Palisades to ENEXUS, a subsidiary of itself. It is seeking the license transfer. So far problems have NOT been fixed: i.e. reactor head, snuffer valves, embrittlement etc. On August 5, there was an incident now under NRC investigation.

2011: Palisades continues to have major issues. December: 2 sump pump failures: hot shutdown, plant tremors with major gas releases. Enough is enough! Shut it down for good before it blows.!! WRITE YOUR CONGRESSPERSON, THE NRC, THE PRESS...SHUT IT DOWN. SHUT IT DOWN NOW!!!

Five public interest organizations filed suit in a Northern California federal district court against the US Department of Transportation (DOT) for its adoption of rules which reduce public protections by allowing more radioactivity to move on roads, rails, planes and waterways without regulatory control. The groups are Nuclear Information and Resource Service, Sierra Club, Public Citizen, Redwood Alliance and Committee to Bridge the Gap. The groups are calling for withdrawal of the portions of the rule that exempt and weaken nuclear transport controls and for full environmental impact review.

The regulations exempt various amounts of every radionuclide (all the radioactive forms of each element) from radioactive labeling, tracking, and control. They also allow some nuclear materials to be shipped without packaging. The groups will also challenge, in a separate case, the Nuclear Regulatory Commission (NRC) which simultaneously adopted the same regulations. A whole new category of exempt quantities has been adopted, allowing radioactive packages (called consignments) to be considered not radioactive in transport. The exempt concentration limits have changed, exempting higher concentrations for more than half of the hundreds of radionuclides listed.

"At a time of heightened concern about dirty bombs, the federal government should not increase the amount of nuclear material that can be transported without any labeling or tracking. This is the exact wrong time to let go of nuclear materials and wastes," stated Diane D'Arrigo, Radioactive Waste Project Director at Nuclear Information and Resource Service. "Watching for and detecting dirty bombs will be harder if more radioactive materials are shipped routinely without placards or manifests."

"Workers and the public will be exposed to radiation without their knowledge or consent. It is forced radiation exposure," charged Wenonah Hauter, director of Public Citizen's Critical Mass Energy and Environment Program.

Truck drivers, rail workers, loaders, emergency responders, even postal workers could be exposed routinely to more radioactivity than before without warning. Workers in the transport and shipping industries will get the highest doses but everyone who lives, works and travels along the routes could come into regular contact with unidentified nuclear waste. According to calculations in the DOT rule, truck drivers could get more radiation from hauling unmarked radioactive materials than one is allowed living next to a nuclear reactor or weapons site. DOT admits workers and the public will have more exposure to radioactivity but discounts the dangers of radiation, failing to consider the impacts on those more susceptible to radiation like children, the fetus, women and those with reduced immunity.

The transport rule fits into a larger picture of deregulating nuclear waste. Other federal agencies including the NRC, the Environmental Protection Agency (EPA) and the Departments of Energy and Defense (DOE, DOD) are in various stages of deregulating nuclear wastes and sites over which they have jurisdiction. If they proceed with deregulating nuclear wastes as now proposed, radioactive materials could go to municipal and industrial landfills, incinerators and scrap recycling centers. Workers at those sites would be regularly exposed to more man-made radiation. Changing the transport regulations makes taking unmarked nuclear loads to unregulated destinations possible once they are cleared by those other agencies.

"Removing existing requirements for labeling in transit will make it easier for other agencies to let nuclear wastes get out into commerce. The public will be exposed both during transport and then again from the products, buildings and roads made from nuclear contaminated materials," explained Dan Hirsch, President of the Committee to Bridge the Gap.

"That is the real motivation," said Dr. Judith Johnsrud of the Sierra Club, "to assist the nuclear industry in treating some nuclear waste as if not radioactive. This saves the nuclear generators money and pushes the economic and health burden onto unsuspecting transporters, recyclers, local governments, the public and the environment."

No meaningful justification for the exemptions is provided by either DOT or NRC for relaxing restrictions on nuclear materials transport. The exempt concentrations and amounts adopted are the same as those recommended by international nuclear advocacy organizations to allow nuclear waste to be cleared for commercial recycling.

"It is not a coincidence. This weakening of the nuclear transport laws is a deliberate attempt to bypass the American public's opposition to nuclear waste deregulation and release into everyday commerce. DOT and NRC are teaming up with the global nuclear industry to make nuclear power appear cheaper while putting transport workers, the public and environment at unnecessary radioactive risk." said Michael Welch of the Redwood Alliance.

For more information on Nuclear Information and Resource Service (NIRS), go to www.nirs.org.

CHICAGO—The much ballyhooed “Nuclear Renaissance” is nothing more than a PR fraud foisted upon an unsuspecting and uninformed public, charge two safe-energy groups today.

<>Kevin Kamps, nuclear researcher for Beyond Nuclear (www.beyondnuclear.org) of Takoma Park, MD, and Dave Kraft, director of the Chicago-based Nuclear Energy Information Service – two organizations critical of nuclear power – maintain that the Nuclear Energy Institute (NEI – the trade group for the US nuclear power industry) has long been inflating the alleged benefits of nuclear power, while keeping the public in the dark about the downsides.

“We refuse to allow the NEI to come to Chicago to perpetuate its fake ‘Nuclear Renaissance’ without a public challenge of its bogus claims,” says Kamps. “This is no ‘renaissance.’ It’s a relapse.” Kamps asserts.

<>The NEI is in Chicago for its 3-day annual conference at the Fairmont Hotel. Exelon Chair John Rowe is chairman of the NEI. Exelon has 14 reactors in Illinois (11 operating), more than any other state.

“At a time when high energy costs and the prospect of catastrophic climate change call for radical changes in how we get our energy, we will not sit by quietly or patiently while PR hacks spew the falsehoods that nuclear power is either economical, or able to help solve the global warming problem,” says NEIS’ Kraft. “The people like the NEI who deliberately spread these falsehoods to make a short-term buck will find that there will be consequences from now on,” Kraft warned.

<>Reality has been very unkind to the Nuclear Renaissance, formally launched at an industry conference at the Palmer House, Chicago, in December 2001. From the heady days of Vice President Cheney’s 2001 call for 150 new reactors and NEI’s claims of reactors costing $1 billion/GW each, today’s headlines talk of maybe 8-10 reactors being built in the US by 2020; and Wall Street and utilities themselves talking about reactors costing $6-$12 billion each.

“Every cost prediction the NEI and the nuclear industry have made has been wrong. Yet, this industry keeps coming back to feed at the public trough,” Kamps points out. “The 2005 energy bill granted over $21 billion in actual and guaranteed subsidies for the nuclear industry, with an additional $30 billion possible in the next year. And even the Lieberman-Warner bill – touted as a bill to support and invest in clean energy sources to fight global warming and due for a vote in early June -- has as much as $500 billion in hidden benefits for the nuclear industry, even though the word nuclear appears no where in the bill,” Kamps notes. “This kind of fraud would make Al Capone blush.”

While nuclear industry predictions about costs have always been undervalued, its claims about its role in fighting global warming seem to trend in the opposite direction according to Kraft.

<>“If global warming is the ‘Titanic’ of all environmental issues, one threatening civilization, then the nuclear industry and NEI are selling seats to the life-boats, and leaky life-boats at that,” Kraft claims. “Nuclear power is simply too slow, too expensive, less carbon-effective and adds other equally dangerous risks compared to other viable choices that exist already to reduce atmospheric carbon. It must be rejected as a ‘solution’ or even a ‘helper’ in the fight against global warming,” Kraft asserts. “It is unconscionable that the NEI continues to perpetuate such a fraud on an ill-informed public.”

Both Kamps and Kraft are quick to point out that as dire as the energy and climate situation appear, viable cost- and environment-effective means already exist to deal with the two crises -- simultaneously.

“Fortunately, such a program has already been researched,” notes Kraft. “It is called, ‘Carbon Free – Nuclear Free by 2050: A Roadmap for US Energy Policy,’ developed by Dr. Arjun Makhijani of the Institute for Energy and Environmental Research (IEER; www.ieer.org ). His calculations show that this country can get off of BOTH fossil and nuclear fuels by mid-century, using technology already largely invented and available, and do so in a cost-effective manner. The economic and environmental benefits of Carbon Free – Nuclear Free are extraordinary, far surpassing those of nuclear power,” Kraft concludes.

<>Both agree that the real barriers to such an energy program are largely political, not technological.

“The influence of the NEI and nuclear industry over the Congress and the regulators at the Nuclear Regulatory Commission is enormous,” Kamps points out. “The tail wagging this dog needs to be swatted hard,” he says.

<>“An old saying notes that, ‘If we keep doing things the same way we’ve always done them, we’re likely to get a whole lot more of what we already got.’ If the NEI and its clients get their way, that means more nuclear waste, higher cost electricity, more nuclear proliferation, and more global warming, since the money used on the fake nuclear ‘renaissance’ would not get spent on more effective means of removing atmospheric carbon,” Kraft asserts.

“All of the candidates running for President are simply more-of-the-same fence sitters,” Kraft says. “Sen. Obama is tragically misguided in his belief that nuclear power needs to be ‘kept on the table’. In spite of the heavy campaign contributions to all the candidates from the nuclear industry people, they all need to break away from this dead-end industry, and launch a real sustainable energy future,” says Kraft

“One that doesn’t suffer from the continual paid PR exaggerations of the NEI,” Kamps concludes.

“Isn’t it time we forgot about nuclear power? Informed capitalists have. Politicians and pundits should too. After more than half a century of devoted effort and a half-trillion dollars of public subsidies, nuclear power still can’t make its way in the market.” – Amory Lovins, Rocky Mt. Institute, “Forget Nuclear.” April 2008. (see above)

<>“This much seems clear: a handful of firms might soak up huge federal subsidies and build one or two overpriced plants. While a new administration might tighten regulations, public safety will continue to be menaced by problems at new as well as older plants. But there will be no massive nuclear renaissance. Talk of such a renaissance, however, helps keep people distracted, their minds off the real project of developing wind, solar, geothermal and tidal kinetics to build a green power grid.” -- Christian Parenti The Nation, May 12, 2008

“It does not make economic sense.” --Warren Buffet, on explaining his decision to end plans to construct a nuclear reactor in Idaho, January, 2008.

-- end --

Radiation-Laced Groundwater Could Be More Widespread

than Entergy Nuclear Palisades Knows or Admits

Concerned Citizens Demand Compulsory Testing in Area and Lake Michigan

On Dec. 10 and 13, the Entergy Nuclear Palisades atomic power plant found concentrations of radioactive hydrogen, called tritium, in groundwater between the reactor and Lake Michigan that violate U.S. Environmental Protection Agency (EPA) Safe Drinking Water Act limits. Entergy Nuclear Palisades detected concentrations of 22,000 picoCuries per liter in the groundwater, above EPA’s 20,000 picoCurie per liter Safe Drinking Water Act limits.

However, technical expert Dr. Arjun Makhijani, President of the Institute for Energy and Environmental Research, reports that "[t]he scientific models used to evaluate the adverse health impacts of tritium have a number of serious weaknesses." Dr. Makhijani reports that "...tritium can cross the placental barrier. This tritium can then be incorporated into an embryo/fetus and irradiate rapidly dividing cells, thereby raising the risk of birth defects, early miscarriages, and other problems. Tritium therefore provides an important case study for examining how radiation protection standards need to be changed in light of risks to those who are not adult men." Dr. Makhijani, citing the vulnerability of embryos and fetuses to tritium’s radioactivity, is calling for Safe Drinking Water Act protections to be strengthened as much as 50 times, as has happened in the State of California; the State of Colorado and U.S. Department of Energy have agreed to protective levels for tritium in groundwater 40 times stronger than the EPA regulations in place at Palisades.

Statement of Kevin Kamps, Radioactive Waste Watchdog at Beyond Nuclear, and board member of Don’t Waste Michigan representing the Kalamazoo chapter, regarding Entergy Nuclear Palisades’ admitted radioactive contamination of groundwater and the necessity for extensive testing of the area’s groundwater, surface water, and drinking water supply, including Lake Michigan itself.

“Entergy Nuclear Palisades’ admitted detections are likely but the tip of a radioactive iceberg in the form of tritium contamination spreading throughout the groundwater below, perhaps even into Lake Michigan itself. Palisades’ admission merely confirms what we have long known – that this nuclear reactor is far from benign, but rather generates and releases harmful radioactivity into the environment. These leaks have undoubtedly worsened as this now forty year old reactor deteriorates and degrades with age.

In our view, it is criminal for Entergy Nuclear Palisades to trivialize, downplay, and explain away the potential health consequences of such tritium contamination in an attempt to deceive the unsuspecting public.

Area residents and visitors near Entergy’s Palisades atomic reactor – especially children, the most vulnerable of all – are at risk from drinking radioactively-contaminated well water or Lake Michigan water. The U.S. Nuclear Regulatory Commission (NRC), EPA, and the State of Michigan should do their job, and determine the health risks to the residents of Palisades Park resort community, CovertTownship, the City of South Haven, visitors to the Van Buren State Park, and other area residents.

As Dr. Arjun Makhijani at the Institute for Energy and Environmental Research has reported, tritium increases the risk not only of cancer, but also of non-cancerous diseases and maladies in pregnant women and the embryo/fetus, including ‘early miscarriages, malformations, and genetic defects. Risks can also be multi-generational given that a woman’s ova are produced while she is in her mother’s womb.’

Poisoned water has been leaking from the Palisades atomic reactor for who knows how long. Radiation has now been detected escaping as an underground radioactive plume, but the question must be asked, has it begun to contaminate Lake Michigan as well? Nearby residents, and visitors at the Van Buren State Park, may very well have unknowingly consumed, cooked in, and bathed with radioactively contaminated water, risking cancer and birth defects with repeated and prolonged exposure. Those swimming and fishing near Palisades, as at Van Buren State Park, may also be at increased risk due to radioactivity releases into the Lake Michigan environment.

Area residents and visitors should not be deceived nor satisfied by hollow claims from Entergy or NRC that exposure to tritium is harmless. This propaganda has already been debunked by the U.S. National Academy of Sciences, which has declared that there is no safe dose – no matter how small – of radiation.

Area residents and visitors to Van Buren State Park must demand their drinking water be independently and fully tested. Neither Entergy Nuclear nor the NRC can be trusted to protect human health against corporate greed. Currently, South Haven’s drinking water authority collects samples of Lake Michigan water from the City’s water intake system, but then hands them over to Entergy Nuclear for safety testing. This is a flagrant violation of basic chain of custody protocols designed to prevent fraud and falsification in scientific safety testing. Extensive on-site and off-site groundwater monitoring should be undertaken immediately. It must be conducted by legitimately independent and trustworthy third parties.

Entergy deceptively reported that the contaminated ‘well is located inside the owner controlled area and inside the protected area. This well is not a drinking water source.’ But they apparently have not even checked off-site groundwater, nor Lake Michigan. Of course, if they do not look for off-site contamination, they will not find it. And of course, all groundwater is potentially drinking water. The Van Buren State Park’s campground, immediately adjacent to Palisades nuclear reactor, uses well water for drinking. And the City of South Haven uses Lake Michigan as a drinking water supply, so leaking tritium entering Lake Michigan could flow from residents’ kitchen sink and bathroom taps as radioactively contaminated drinking, cooking, and shower water.

NRC has allowed Palisades’ now-closed sister atomic reactor, Big Rock up north in Charlevoix, to discharge 20,000 gallons of tritium contaminated water into Lake Michigan first via the soil, then via the groundwater, like a radioactive septic field. Given the proximity of area drinking water supply intakes in Lake Michigan, this outrage cannot be repeated at Palisades.”

The Canadian nuclear industry and government are proposing to bury all of Ontario's "low" and "intermediate" level radioactive wastes 1 kilometer (0.6 miles) from the Lake Huron shoreline at the Bruce Nuclear Complex, just 50 miles east across Lake Huron from Michigan. Ontario has a whopping 20 nuclear reactors (by comparison, Illinois is the U.S. state with the most reactors, with "just" 12 operating reactors; Michigan has "just" 4 still-operating reactors, and 1 permanently shutdown reactor).

These so-called "low" and "intermediate" level radioactive wastes contain all of the same radioactive poisons as high-level radioactive waste, only in lesser concentrations. The long-lasting radioactive poisons in these wastes include cesium-137, strontium-90, plutonium-239, iodine-129, and nickel-59, to name but a few of the hundreds of radioactive poisons present in the waste. They have a hazardous persistence of about (or longer than) 300 years, 300 years, 240,000 years, 170 million years, and 800,000 years, to give you an idea how long they will remain dangerous to human and ecosystem health. Given the fact that Lake Huron is the drinking water supply for many millions of people downstream including in Michigan this plan is unacceptable, given the risk that a dump that close to the lake would leak over such long time periods.

Such a dump would also set a precedent for dumping radioactive wastes on the shorelines of the Great Lakes elsewhere. And at the Bruce Nuclear Complex in Canada, it could pave the way for all of Canada's high-level radioactive wastes to be dumped at Bruce as well.

This dump needs to be stopped in its tracks, and the Michigan environmental movement is just the group of folks to do it!

Group Statement to Canadian Nuclear Safety Commission:

September 22, 2006

From:

Kevin Kamps

Nuclear Waste Specialist

Radioactive Waste Project

Nuclear Information and Resource Service (NIRS)

6930 Carroll Avenue, Suite 340

Takoma Park, Maryland 20912-4423

Phone (301) 270-6477 extension 14

Fax (301) 270-4291

Kevin@nirs.org

www.nirs.org

on behalf of Lone Tree Council, West Michigan Environmental Action Council, Michigan Coalition on the Environment and Jewish Life (MI-COEJL), Coalition for a Nuclear-Free Great Lakes, Don't Waste Michigan, Citizens Resistance at Fermi Two (CRAFT), Nuclear-Free Great Lakes Campaign, Green Party of Michigan, Van Buren County Greens, Citizens for Alternatives to Chemical Contamination, Environmental Coalition on Nuclear Power, Environment Michigan, Voices for Earth Justice, and additional concerned citizens (see full contact information listed at the end of this submission)

To:

Canadian Nuclear Safety Commission

Attn: Michael Rinker, Environmental Assessment Specialist

Environmental Assessment and Protection Division

P.O. Box 1046, Station B

Ottawa, ON K1P 5S9

Phone: 1-800-668-5284 Fax: (613) 995-5086

E-mail: ceaainfo@cnsc-ccsn.gc.ca

Re: Comment on the Proposed Scoping Document (Environmental Assessment Guidelines) for Ontario Power Generation's Proposal for a Deep Geologic Repository for disposal of "low" and intermediate level radioactive wastes in Kincardine, Ontario, Canada

[Submitted via email to ceaainfo@cnsc-ccsn.gc.ca, as well as via Fax to (613) 995-5086]

Dear Mr. Rinker,

We are writing to express our concern about Ontario Power Generation's proposal for a deep underground radioactive waste dump at its Bruce nuclear site in Kincardine, Ontario, Canada only one kilometer (0.62 miles) from the shore of Lake Huron.

We are very disappointed that the staff of the Canadian Nuclear Safety Commission (CNSC) has failed to support an upgrade of the current environmental assessment from a Comprehensive Study to an independent Panel Review. There are three important reasons to do so. First, an independent review panel would ensure a fair hearing, keeping the process at arm's length from the CNSC, which is too close to the nuclear industry. Second, until now, radioactive waste has only been kept in temporary storage facilities, and this proposal would set an historic precedent for permanent deep underground disposal of radioactive waste in Canada and the Great Lakes Basin. Thirdly, because it is so long-lived and has the potential to affect human health and the environment for many generations to come, the public has always been very concerned about radioactive waste disposal, both in Canada, the United States, and in First Nations and Native American Nations throughout the Great Lakes Basin.

While I understand that CNSC staff has expanded the alternatives being considered, alternatives should include monitored, retrievable "interim" storage at the nuclear sites that generated the wastes in the first place, and "reduction at source" of radioactive waste through nuclear phase-out.

In terms of the study area for the assessment, the proposed dump has potential environmental impacts not just locally and regionally, but internationally as well. Because the radioactive wastes will remain toxic for hundreds of thousands of years, the dump is a threat not only to this generation, but to thousands of human generations into the future, and not only to the locality and the region around the Bruce nuclear complex, but also to downstream communities on the Great Lakes in Canada and the United States of America, as well as to First Nations and Native American communities. CNSC staff has rejected any possibility that the dump could have trans-boundary impacts. However, research and documents published by the International Joint Commission on Great Lakes Water Quality make it clear that Canadian nuclear facilities on the Great Lakes have had measurable trans-boundary effects, as have U.S. nuclear facilities. The study area should be expanded to include communities on the Lake Huron shoreline in both the U.S. and Canada, as well as extended to include communities downstream of Bruce that draw their drinking water from Lake Huron and points downstream.

The following important issues also need to be addressed:

-- the lack of Canadian federal policy on the long-term management of low and intermediate level radioactive waste;

-- inclusion of decommissioning waste in planning for the Bruce facility;

-- extension of the assessment time to one million years because of the long lifetime of some radioactive elements in low and intermediate level radioactive waste;

-- detailed examination of the safety of radioactive waste transportation from the Pickering and Darlington sites to the Bruce site;

-- alternatives to radioactive waste incineration;

-- municipalities on transportation routes should be consulted on the initiation of further decades of radioactive waste transportation through their communities; and

-- costing and economic analysis of the main proposal and all alternatives should be mandatory.

We would also like to tentatively reserve speaking slots for the submission of oral presentations at the Monday, October 23, 2006 CNSC hearing in Kincardine, Ontario, Canada regarding this matter, for representatives of our organizations that may be able to attend this hearing despite the very long travel distances that would be required to attend.

Whether as written or oral submissions, we will continue to communicate to the CNSC our deep concerns about, and objections to, the concentration of radioactive wastes from a score of nuclear reactors across Ontario, and the risk of catastrophic radioactive contamination to Lake Huron and points downstream, if these accumulated wastes begin to leak out from the proposed burial dump just 1 kilometer (0.6 miles) from the shoreline of Lake Huron. Our coalition of groups and individuals deeply troubled about this dangerous proposal continues to grow in Michigan, and we will share with CNSC and other Canadian, U.S., and First Nations decision-makers an updated list of organizations objecting to this radioactive waste dump in the heart of the Great Lakes by the time of the October 23rd CNSC hearing.

We would also like to express our endorsement of the comments submitted by Dave Martin, Energy Coordinator, Greenpeace Canada and S. (Ziggy) Kleinau, Coordinator, Citizens for Renewable Energy, to CNSC as a part of this proceeding.

We also request a copy of the revised scoping document, CMD 06-H22. Our postal and email addresses are given below, so that you can either mail a hard copy of this document, or email us an electronic version or Internet link. This document is not posted on the CNSC web site, which has unfortunately made our participation in this proceeding more difficult. We respectfully request that all documents pertaining to this proceeding be posted to CNSC's website, as well as provided directly to us either through the mail or email, to facilitate our participation in this proceeding.

Please also send us any information or application forms pertaining to intervener funding, for those of us who wish to intervene in this environmental assessment proceeding.

Please consider our concerns. Thank you.

Sincerely,

Kevin Kamps

Nuclear Waste Specialist

Nuclear Information and Resource Service

Terry R. Miller, Chairman

Lone Tree Council

Bay City, MI 48706

Thomas Leonard, Executive Director

West Michigan Environmental Action Council

Grand Rapids, MI 49506

Sara Bernstein, Program Manager and Betsy Winkelman, Co-Chair

Michigan Coalition on the Environment and Jewish Life (MI-COEJL)

Bloomfield Hills, MI 48301

Michael Keegan

Coalition for a Nuclear-Free Great Lakes

Monroe, Michigan 48161

Alice Hirt

Don't Waste Michigan

Holland, Michigan 49423

Keith Gunter

Citizens Resistance at Fermi Two (CRAFT) and Nuclear-Free Great Lakes Campaign

After recent earthquakes and aftershocks in the Midwest...the biggest ever....nuclear waste officials reportedly checked the Palisades and DC Cook nuclear power plants for cracks and fissures.

Since then there have been plant shut downs.

The possibility of earthquakes and the shifting sands that the nuclear waste storage casks are on was one of the concerns of DWM members at the relicensing talks with the NRC.

As time goes on, DWM concerns are becoming a reality.

Prior to September 11, 2001, DWM members voiced and wrote concerns to the NRC about the threat of terrorism if a large airplane was run into a nuclear power plant or a bomb dropped on them.

Other concerns were about ground terrorism.

There are yet numerous concerns about the lack of adequate security to protect the public from terrorism. DWM members believe these concerns have not been adequately addressed, nor have nuclear power plant safety issues.

Public comment:

I am against the transfer of nuclear licenses. When the NRC issues a license to a particular corporation or entity it is with the understanding that the will of the NRC towards needed improvements etc. be done. When the licensee sells or transfers those licenses, the next entity should be required to either fulfill the obligations set forth or to supplicate the NRC again.

It would be best not to allow a transfer. That would stop some of the deceptions and help protect the public and the environment more. This is not the sort of thing to leave open loopholes on.

Sincerely,

Kathryn Barnes

DON'T WASTE MICHIGAN

SHERWOOD CHAPTER

Uranium claims spring up along Grand Canyon rim

RESOURCE: Contamination of the Colorado River is just one concern about the claims. “If you can’t stop mining at the Grand Canyon, where can you stop it?” asks one opponent.

A rush to extract uranium on public lands pits environmentalists, who worry about the local effect, against mining companies, which point out that nuclear power wouldn't contribute to global warming.

By Judy Pasternak, Los Angeles Times Staff Writer

May 4, 2008

GRAND CANYON NATIONAL PARK, ARIZ. -- Thanks to renewed interest in nuclear power, the United States is on the verge of a uranium mining boom, and nowhere is the hurry to stake claims more pronounced than in the districts flanking the Grand Canyon's storied sandstone cliffs.

On public lands within five miles of Grand Canyon National Park, there are now more than 1,100 uranium claims, compared with just 10 in January 2003, according to data from the Department of the Interior.

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Seeking to mine uranium

Western claims

In recent months, the uranium rush has spawned a clash as epic as the canyon's 18-mile chasm, with both sides claiming to be working for the good of the planet.

Environmental organizations have appealed to federal courts and Congress to halt any drilling on the grounds that mining so close to such a rare piece of the nation's patrimony could prove ruinous for the canyon's visitors and wildlife alike.

Mining companies say the raw material they seek is important to the environment, too: The uranium would feed nuclear reactors that could -- unlike coal and natural gas -- produce electricity without contributing to global warming.

And uranium is in short supply. In recent years, mines closed in Canada and West Africa, yet the United States as well as France and other European countries have announced intentions to expand nuclear power. Predictably, the price of uranium has soared -- to $65 a pound as of last week, from $9.70 a pound in 2002.

In the five Western states where uranium is mined in the U.S., 4,333 new claims were filed in 2004, according to the Interior Department; last year the number had swelled to 43,153.

The push to extract more uranium has caused controversy not just involving federal land but private and state land as well. In Virginia, a company's plan to operate in a never-mined deposit spurred a hearing in the Legislature. In New Mexico, a Navajo activist group is challenging in federal court a license issued just over the reservation's east border.

Uranium claims are also encroaching on stretches of Western parkland such as Arches National Park, Capitol Reef National Park and Canyonlands National Park, all in Utah, as well as a proposed wilderness area in Colorado called the Dolores River Canyon.

But by far the most claims staked near any national park are in the vicinity of the Grand Canyon, which draws 5 million people a year. The park is second in popularity only to the Great Smoky Mountains of North Carolina and Tennessee.

"If you can't stop mining at the Grand Canyon, where can you stop it?" asked Richard Wiles, executive director of the Environmental Working Group.

The energy-versus-environment debate is apparent within the Interior Department, which granted the mining claims through its Bureau of Land Management. Among the mining critics is Steve Martin, superintendent of the Grand Canyon park and an Interior Department employee himself. "There should be some places that you just do not mine," Martin said.

Uranium is "a special concern," he added, because it is both a toxic heavy metal and a source of radiation. He worries about uranium escaping into the local water, and about its effect on fish in the Colorado River at the bottom of the gorge, and on the bald eagles, California condors and bighorn sheep that depend on the canyon's seeps and springs. More than a third of the canyon's species would be affected if water quality suffered, he said.

Martin is not the only one uneasy about potential water contamination. Add to the list the Metropolitan Water District of Los Angeles, which sells wholesale water throughout Southern California from its Colorado River Aqueduct. "In addition to the public health impacts, exploration and mining of radioactive material near a drinking water source may impact the public's confidence in the safety and reliability of the water supply," the district's general manager, Jeffrey Kightlinger, wrote in March to Interior Secretary Dirk Kempthorne.

No one is mining near the Grand Canyon yet, but wooden claim stakes can be spotted throughout the brush-covered plains north and south of the park.

Vane Minerals, a British company, applied last year to start exploratory drilling on seven sites in the Kaibab National Forest, near the canyon's popular South Rim.

Under current mining law the Forest Service had no choice but to allow the drilling, Regional Forester Corbin Newman testified in March to Congress. The mission of a national forest is different from that of a national park, he pointed out. Indeed, signs at the Kaibab Forest's border proclaim that visitors are entering the "Land of Many Uses."

In response to the approval, the Grand Canyon Trust, the Center for Biological Diversity and the Sierra Club sued in federal court, alleging that the Forest Service didn't thoroughly investigate the environmental effect of drilling and prospective mining. In April, a judge issued a temporary restraining order until the case could be heard, probably in the summer.

Drilling had already begun near Deer Tank Wash just off a dirt road about five miles from the canyon park's east entrance. Now, the only signs of that activity are a 6-inch pipe sticking up half a foot from the ground near a large piñon tree, and hay scattered in the mud.

The wash is prone to flooding, said Taylor McKinnon, a public lands advocate for the Center for Biological Diversity. "Would the water from a flash flood go through the bore hole to the aquifer? We don't know because there wasn't an analysis," he said.

Meanwhile, five additional proposals for exploratory drilling have recently been submitted to the Kaibab National Forest, according to Newman. And three old uranium mines near the canyon park are on standby, ready to resume operations.

Many of the companies are based abroad, said McKinnon, so their directors don't understand the special place that the Grand Canyon holds in this country's lore: "What if an American company went to drill at Stonehenge?"

But the region is special in another way, said Kris Hefton, chief executive of Vane's American uranium operation. The uranium is found in "breccia pipes," contained geological formations that hold higher-grade deposits than elsewhere in the U.S., he said.

Breccia pipe mines can be compact, less than 20 acres in size, and uranium producers say they are among the easiest to restore after mining is done. And because the ore holds so much uranium, it's cheaper to mine. "They're not as susceptible if the price drops," Hefton said, adding that mining can be profitable in the region even if uranium fetches only $20 a pound.

"You won't have to depend on foreign uranium," he said. Though higher-grade deposits are found in Canada, and more mines are opening in the next five years, "you never know what the Canadians will do. It just makes sense to protect our industry from a national security standpoint."

Nevertheless, Rep. Raul M. Grijalva (D-Ariz.) has introduced a bill that would withdraw a million acres of federal land around the Grand Canyon park from future mining and mineral leases. The bill would not affect the claims already staked if they are found to contain uranium deposits.

And so uranium mining could end up being part of the view at Gunsight Point, a promontory north of the park at the end of a rutted dirt road on public land. There, two striking gorges merge into one, with a dry wash at the bottom of Snake Gulch coming in from the east and Kanab Creek flowing in from the west.

Overlooking the creek are 14 uranium claims, according to an analysis of Interior Department data by the Environmental Working Group. The claims are held by companies such as Energy Metals and Uranium One Ventures, and by an official with Quaterra Resources Inc., which boasts to investors that it is "one of the largest claim holders in the Arizona Strip District."

On a hazy morning, the canyon is still visible downstream. And Martin, charged with its protection, is apprehensive. His experience with uranium mines is confined to one that actually operated right at the canyon's edge, grandfathered in because it opened before Congress created the national park in 1919. The U.S. bought the site in 1962, and mining stopped in 1969.

Now the remains of the aerial tram that carried the ore can be seen at the South Rim. Special strips have been placed atop the structure to keep California condors from resting there, to protect them from lightning strikes. And a chain-link fence keeps hikers away from mine wastes.

Elevated radiation has been detected in Horn Creek below, and signs have been posted warning visitors not to drink the water. A National Park Service sign explains to the public that uranium deposits also lie just outside the park.

"What does the future hold?" the note asks, and concludes: "Mines and other industry near parks often bring unforeseen impacts on park resources."

The Nuclear Regulatory Commission staff met with representatives of Entergy Nuclear Operations on Monday, May 12, to discuss the agency’s assessment of the safety performance during 2007 at the Palisades Nuclear Power Plant. The plant is located in Covert, Mich.

The meeting, which was open to the public, began at 6:00 p.m. EDT at Lake Michigan College, 125 Veteran Boulevard, in South Haven. The NRC staff presented the results of the assessment, talk about the NRC and its range of activities, and responded to questions or comments from the public about the NRC’s oversight before the close of the meeting.

Members of Don't Waste Michigan brought up the following issues:

*The reactor lid has not been replaced

*The reactor is operating with potentially flawed snubber valves

*Embrittlement

^Defective cask 4

*Shifting sands under the high-level radioactive waste pad

*Plant security issues

*Tritium Groundwater contamination

from a leak at Palisades

*Checking for cracks after the earthquake. Is a "walk through" enough? DWM felt that cracks could not be detected within the concrete without radiological testing.

The public was also concerned that Entergy did not stay to respond to the public's concerns and many felt that the NRC does not do enough to safeguard the public or make Entergy spend money to do the repairs Consumer's Energy had promised to do in order to relicense the aging plant. After the re-licensing, CE sold the plant to Entergy.

Monday May 12th 6 pm: Public Meeting with the NRC re: Palisades at Lake Michigan College, South Haven. IGE and DWM members attended. NOTES from Corrine.

IN MEMORY OF:

Eunice Hendricks

Eunice was an educator and environmentalist who won legislation to create environmental areas in the public schools. A gentle, gracious person, Eunice was deeply mourned by other DWM members. She thought one of the most important things we need to do it to educate children about the natural world and provide living, natural environments where children can learn about the Creation as a living thing to care for beyond the realm of books.

LeRoy Wollins

LeRoy became involved with the DWM fight to stop the re-licensing of Palisades Nuclear Power plant. A member and founder of Veterans for Peace, LeRoy fought to end the cold war and to create a world of peace.

He was active up to the day he passed away on his way to a meeting with the Nuclear Regulatory Agency to try to stop the relicensing of Palisades. LeRoy was an epic hero. All who knew him realized his greatness, his big heart, his courage.

He will be missed by all members of DWMi.

John Clark, PhD. Biochemist

John fought for standards for organic farming and was a Professor at Michigan State University and on an advisory panel to the Governor (Blanchard)…always against the use of pesticides and for environmental integrity. John was a true friend.

As a Michigan resident, I have seen the environment deteriorate around the Great Lakes in my lifetime. The water in Lake Michigan near the Palisades nuclear power plant is full of algae, even though it is cold. The plant has operated for almost 40 years, and wants a 20 year extension.

I believe because of the embrittlement of Palisades, and because of the history of problems with the plant, including staff/management problems and repair backlogs, and after speaking with local residents and finding that there is a cancer pocket in the beach community, and that Palisades has repeatedly asked for safety exceptions to keep operating, one can only conclude that this is a nuclear reactor that is past due, and should not be re-licensed.

The accumulation of nuclear waste along the shore of Lake Michigan is not only a potential terrorist target, as is the reactor itself, but there are also problems with the casks themselves, and the geological strata of the area, which includes the unstable sands which the cask pad sets on. Nuclear waste that is headed for dumpsites built on native lands is "environmental racism" and more operation and creation of wastes should be considered as such.

The NRC analysis and data collection I believe is a flawed system. Too much is left to the reporting by the nuclear industry itself, and the use of generic models to project aging features is not realistic, as each nuclear reactor has a specific set of unique problems, and differentials including weather, changes in staffing, and a host of other issues not projected by generic analysis.

The public is not given enough notification about the meetings, and the meetings are few and poorly scheduled for times most can not attend. The public is expected to offer comments on the EIS and scope and screening etc. without adequate preparation.

Although the current license is valid through 2011, at this time, 2005, an extension is being sought and the time allotted for public comment, debate, and even awareness is under pressure and time constraints. What is the rush?

I would like to request an extension beyond August 22 for public comment on the scope of the Palisades-specific supplement to the generic environmental impact statement for a much later date after the public is aware of such documentation and such is offered.

Further, I would ask as I have at public meetings, that the certain essential elements not be excluded from evaluation.

1.The public health records of the surrounding counties and downwind regions of Palisades. Also, the correlation between the cancer and infant mortality rate as it parallels the plant in operational mode v. shut down status.

2.The track record of Palisades. The lack of reporting problems, and the problems that have been found.

3. The history of the standards by which Palisades has been overseen by the NRC, including a list of the times when the NRC made concessions to the facility in lieu of prior standards and regulations.

4. The actual and complete analysis of the plant by a scientific and independent agency, and not by Palisades or its subsidiaries, and an analysis not dependent on documentation by Palisades, but based on the actual scientific evaluation of the current status of the facility, including, but not limited to embrittlement.

5.Since the water of the Great Lakes is being bottled and sold as drinking water, it is an invaluable resource to the citizens of the region and the world. It is not enough to repair problems as they occur, but it is imperative to put an end to the premise that such repairs will always be possible, and in acknowledging that with a cracked and aging nuclear facility i.e. Palisades, it is not worth the risk to keep it running. The plant can be replaced by wind turbines which will not be a public liability and which will not endanger the environment and which will produce a profit and not need taxpayer subsidies to maintain.

Don't Waste Michigan members attended the 2008 meeting held by the Nuclear Regulatory Agency

(Three of the NRC officials are in the photo here) at Lake Michigan College in South Haven.

This meeting was also attended for a brief time by members of ENTERGY, which operated Palisades until they formed a new company within themselves, with a new name. i.e.Enexus Energy Corporation, the nation's first stand-alone, publicly traded nuclear-energy generating and marketing company. Enexus was created by the spin-off of six reactors at five of Entergy Corporation’s nuclear plant sites into a new company and is based in Jackson, Mississippi. It owns approximately 5,000 megawatts nuclear power generation.

DWM members brought up issues about safety and security at Palisades. The NRC did a follow up on nuclear power plant security issues, and the security team at DC Cook was laid off because they were not watching the security cameras. Later issues at Palisades included an incident when workers were locked down and unable to exit a reactor area where they were working as all the exit doors were closed and the telephone did not work. They were locked in for five hours until the next shift came on.

In previous incidences, there have been safety valves that did not function at Palisades because they were glued down, trespassing on the reactor site area, missing nuclear waste, etc.

Internal sabotage?

DWM members brought up issues about the reactor vessel head which needed replacing and has not been replaced, and of cracking snuffer valves, a defective nuclear waste storage cask, shifting sands/instability of the site etc.

It is unclear what the NRC will do to remedy these problems. The representatives of Enexus, AKA Entergy, did not stay long enough to answer any of the issues.

The NRC will hold another yearly public meeting-Palisades review in 2009. TBA...if it is like that past, DWM members will have little time as notification is often a day or two ahead of a meeting. With little advance notice, it is difficult to get the public involved. DWM has mentioned this problem/issue before, and the NRC has defended itself. If a major accident occurs at Palisades, there will be little justification or defense for Palisades existence and operation or the way the NRC has handled issues.

Fire in the Hole! DC Cook fire rages for nearly a half hour before fire fighters were able to quench the blaze..the nuclear plant released gas into the atmosphere and the fuel rods were kept in the H2O pool while the fire blazed in the generator site.....Palisades leaks tritium into groundwater......DC Cook security fired for not watching security cameras.....Palisades workers go to repair broken valves and fuel leaks...workers are locked in with no telephone access or way out for five hours until the next shift came on......the NRC is investigating........Canada pumps up for its great nuclear waste dump on the edge and under Lake Huron...FERMI SHAKES DOWN

FUKUSHIMA MELTS DOWN

ANYONE NEED MORE REASONS WHY TO SHUT DOWN NUCLEAR REACTORS AND NOT BUILD NEW ONES???

History of DWM: Don't Waste Michigan (DWM) is a group of concerned citizens and organizations initially formed to prevent Michigan from becoming a nuclear waste dump for the entire region. Citizens throughout the state organized to stop the federal government in conjunction with the nuclear power industry from targeting Michigan to become a nuclear waste dump. DWM organized town meetings and rallies at the state Capitol and convinced legislators that a nuclear dump in Michigan was not acceptable. The campaign was successful, not only in stopping Michigan from becoming a nuclear waste dump, but in also educating the public. DWM continues to be active and to educate the public about nuclear waste, Mixed Oxide Fuel, Palisades Re-licensing and other nuclear issues. DWM frequently joins in coalition with environmental groups and conducts a series of conference under the banner Nuclear Free Great Lakes Action Camps from 1999, 2000, 2001, 2002. DWM has intervened in Federal Court with regards to weapons grade plutonium in the form of Mixed Oxide Fuel (MOX). DWM has intervened in Re-licensing hearings at Palisades and Big Rock. DWM continues to monitor nuclear power related issues in Michigan. Don't Waste Michigan is comprised of an active membership of 40 researchers and educators. Membership frequently swells during campaigns. Membership was in the thousands during the height of the nuclear waste dump struggle.

Minutes:Members signed petitions for greater nuclear safety (NEIS), for public meetings and EIS (Tri-Valley Cares) re:biodefense, and mailed cards to Gen.Sec. Annan of the UN for world peace. Discussion about a women's coalition to speak with Michigan's first woman governor on nuclear issues, joining in the clean water campaign, to renew contact with former DWM members, and about current concerns such as the adequacy/inadequacy of "no-fly zones" over nuclear reactors which border Michigan, and the situation of nuclear waste and DU transport through Michigan. Members felt national security can not insure against the threat of terrorism or accidents and it is only a matter of time before a catastrophe, especially since the beginning of the Iraq war.

What you can do:. Write to your representatives and stress the importance of shutting down aging and unsafe nuclear reactors, securing reactor sites from the threats of terrorism and accidents, tracking down loose nukes here in the US, and of supporting the implementation of safe, renewable energy technologies, i.e. wind, water, solar, and geothermal power...

Reuse

Reduce

Recycle

Live in Harmony with the earth...plant a garden, listen to the sounds of nature, learn about nature and interconnectedness....

DWM members attended the Peace Conference in Grand Rapids, March 2005. Over 20 groups were represented, including the Women in Black, IGE, KNOW, Green Party, Greater Grand Rapids Food Systems, Peace Presence, Friends Committee, Holland Peacemakers, Tibet Michigan, and others. DWM members Corrine Carey and Kathryn Barnes spoke and gave a slide presentation about peace actions at the Nevada test site and other areas. The conference was a great success.

DWM members attended the Binational Forum in Monroe, Michigan in 2007. Guest speakers included: Kevin Kamps of Beyond Nuclear, Professor Edwards Ph.D., President, Canadian Coalition for Nuclear Responsibility, Ziggy Kleinhaus of Citizens for Renewable Energy, David Gard, Energy Program Director, Michigan Environmental Council, Lansing, Alexis Raney, Director of Save the Wild U.P, Doris Allen, President of Voices for Earth Justice and Great Lakes songwriter and troubadour, Victor McManemy. The forum was a great success. It was educational and inspiring and free with refreshments and music, thanks to sponsors Harold Stokes and CACC and others.

Monroe, MI... Last night filing deadline to comment on the proposed Fermi 3 Reactor did not pass without a flurry of complex legal challenges being launched. Several dozen Interventions were filed as both comments on the Draft Environmental Impact Statement (DEIS) and more formalized legal contentions were filed with the Atomic Safety and Licensing Board (ASLB). The DEIS comments fall under the jurisdiction of the National Environmental Policy Act (NEPA) and the more legal contentions filed with the ASLB fall under the jurisdiction of the Atomic Energy Act.*

The legal contentions ran the gamut including challenges on the actual need for a Fermi 3 reactor and the economics; wetlands decimation; water intakes at risk; health impacts; First Nation treaty rights; fisheries in jeopardy; thermal pollution of Lake Erie; dangerous fuel enrichment. The comments addressed areas that were clearly overlooked and omitted from the Environmental Review process, and areas which were poorly evaluated. Once again these comments were robust and comprehensive. Please find attached just a small sample of the comments made. The legal contentions before the ASLB are attached as 'Intrvnrs Comment letter Complete'. The legal Intervenors will be posting several dozen comments to the Beyond Nuclear webpage in the next few days.

For more detailed information, there are six downloadable documents to the left in pdf and ms word format.